Requirements
Contracts with educational institutions must follow the OMB Uniform Guidance for cost allowability, and agencies should not add extra cost restrictions.
Overview
FAR 31.303 establishes the requirements for determining allowable costs on contracts with educational institutions. It mandates that contracts referencing FAR Subpart 31.3 must use the cost principles found in the OMB Uniform Guidance at 2 CFR part 200, subpart E, and appendix III, as in effect on the contract date. The section also clarifies that agencies should not impose additional restrictions on individual cost items beyond those in the OMB Uniform Guidance.
Key Rules
- Reference to OMB Uniform Guidance
- Contracts with educational institutions must determine cost allowability according to 2 CFR part 200, subpart E, and appendix III, not just FAR cost principles.
- No Additional Agency Restrictions
- Agencies are discouraged from adding further restrictions on specific cost items beyond what is already in the OMB Uniform Guidance.
Responsibilities
- Contracting Officers: Must apply the OMB Uniform Guidance cost principles when determining allowable costs for contracts with educational institutions and avoid imposing extra restrictions.
- Contractors (Educational Institutions): Must comply with the cost principles in 2 CFR part 200, subpart E, and appendix III, as referenced in their contracts.
- Agencies: Should ensure compliance with the OMB Uniform Guidance and refrain from adding unnecessary cost restrictions.
Practical Implications
- This section ensures consistency in cost allowability for educational institutions by aligning with federal-wide cost principles.
- Contractors must be familiar with the OMB Uniform Guidance, not just the FAR, for cost allowability.
- Common pitfalls include applying outdated guidance or imposing unauthorized cost restrictions.